Venue Transaction Reporting Obligations for third country Trading Participants

As part of its Brexit programme, Cboe Europe Equities (Cboe) would like to remind Participants about the transaction
reporting requirement imposed on a trading venue when Participants conduct cross border trading. Cross border
trading in this context is defined as trading activity conducted on a Cboe venue that is outside of the jurisdiction
that the Participant entity is registered. Cboe EU is scheduled to launch on Monday 1st April (Postponed), unless political developments would cause it to alter this date,
and will require all 3rd country firms who wish to trade on this venue, to have a transaction reporting solution in
place. We are aligning our UAT environment with this scenario in order that firms can test for the most extreme
outcome. To ensure continuity of access in the event of a hard Brexit, impacted Participants need to certify for
a transaction reporting solution by Friday 15th March 2019.

Impacted Participants

Existing non UK or EEA regulated firms will need to continue to transaction report on the relevant Cboe
venue, as appropriate.

Post-Brexit, the following Participants will additionally be in scope:

Trading activity in scope

The only trading activity that is exempt from transaction reporting is end of day on-exchange trade reports
(ETRs) that are used for settlement purposes.

Cboe Europe Venue

Jurisdiction of the country that the firm is regulated in

Trading Activity

EU

External to EEA (i.e. UK, Swiss, etc.)

Order Book Executions
Cboe LIS Direct User
Cboe LIS Designated Broker
Single Party ETR not submitted for EOD settlement
Multi-Party ETR not submitted for EOD settlement
Third Party Broker ETR

UK

External to UK (i.e. EEA, Swiss, etc.)

Order Book Executions
Cboe LIS Direct User
Cboe LIS Designated Broker
Single Party ETR not submitted for EOD settlement
Multi-Party ETR not submitted for EOD settlement
Third Party Broker ETR

Transaction Reporting Solutions

Cboe Regulatory Transaction Reporting Gateway
Participants can use the Cboe Regulatory Transaction Reporting Gateway (RTRG) service to submit transaction
reports to Cboe Europe who will then forward them onto the required regulator. The specification for this
service can be found here
and Participants who need to begin using this service should contact Trade Desk
to begin on-boarding .

Cboe Deal Capacity Offering

The introduction of participant short code information on orders through MIFID II means that (if used
correctly) Cboe Europe have the information required to generate transaction reports for clients conducting
trading activity in a Deal (Principal) capacity. Participants opting in to this offering will have
transactions for their order book executions generated and sent to the required regulator by Cboe. Please
note that at this time, ETRs are excluded from this service and therefore any non EOD ETR
transactions will need to be submitted to Cboe Europe via the RTRG.

Participants can opt in to this offering at a bank code (clearing firm) level. Any bank codes that have
opted in, which submit orders matching the below, along with any non EOD ETRs, will be
rejected:

AOTC (Agency) orders

MITCH (Riskless) orders

Orders submitted without both an execution and investment short code

Orders submitted with non-registered short codes. For a registration to be considered valid, it must be
uploaded by 5am UK time on the day it is to be used. Any registrations after this time will not take
effect until the next trading day.

In addition, Participants must:

use the Side flag on their orders to indicate if they are short selling; and,

Participants will be able to elect to opt in to this functionality in Certification (UAT) from Monday
25th February 2019. Participants wishing to use this offering should contact their
Account Manager who can provide the next
steps.

Certification Deadlines

Impacted Participants who have not certified for a transaction reporting solution by Friday 15th March
2019 will risk having any existing UK or EU bank codes (depending on entity registration) suspended from
trading post-Brexit.